AnthonyB

It's possible to keep the original doors if the FRA can justify it - several large hotel chains have fire doors of this original type to their bedrooms, only upgrading stair and cross corridor doors - and one large provider when faced with enforcement action to add strips and smoke seals to bedroom doors took the issue to determination and won and the enforcing authority had to withdraw the enforcement notice and legal action as a result. Determinations do not set precedents, but do show that it is possible to follow a different course of action, the current legislation does not expect all aspects of an existing premises to be immediately brought up to current standards and the FRA will determine if there difference between the new & old is such it presents an intolerable risk. Are intumescent seals and smoke brushes good - yes! Do they result in far better fire doorset performance - yes! But did old style fire doors in premises that suffered major fires perform well enough to protect the occupiers and large parts of the property - yes on many, many occasions! Even in flats the draft for the new fire safety guidance (for smaller blocks - the guidance is being split into two documents) allows original fire doors to be retained in certain situations. Hotels in the 1980's usually only had corridor detection and it was found that rebate only fire doors would pyrolyze & char around the edges and whilst still intact and holding back a degree of fire/heat and smoke the smoke produced from the pyrolysis of the door was tarry, thick and heavy leading to a smoke layer in the corridor that wasn't always high enough to activate a ceiling detector. As a result the 1988 revision of the fire alarm standard BS5839-1 introduced for the first time Categories of fire alarm system of which the new minimum category of detection (L3) required detection in bedrooms (in fact any room opening into an escape route) so the alarm would sound way before the old style fire door would be compromised. Most hotels are now even more protected with L2 or even L1 systems and this has formed part of the mitigation case for some hotels.

Firstly the fire regulations apply even if no one is employed there - it's a common misconception that you need to have 5 or more employees before they apply. The only relaxation in the legislation for premises occupied by less than 5 employees is that the fire risk assessment (which must always be carried out) doesn't need to be recorded unless the premises requires a license. Normally the stair would be protected (fire doors etc), but as the 1st floor has an alternative escape and the ground floor rooms are still OK based on travel distance to the front door your fire risk assessment could find that, whilst always beneficial, fire doors/protection is not mandatory.

Do you mean the wall behind the cooker as oppose to the back of the cooker itself? What is the wall constructed of and lined with currently? Tiling or other heat insulation behind cookers is common as the heat from the appliance will, over time, damage and degrade a standard plasterboard and stud internal wall. Also certain linings on walls could be a fire risk if subjected to prolonged heat. You don't have to use tiles, however whatever is there should be non combustible.

HI, The equipment is the same for a Part 1 commercial and Part 6 Grade A residential system, but the installation standards do vary depending if it's commercial or residential as they are covered by separate British Standards. If the mixed system is being installed as per LACORS on the basis of a non Building Regulations compliant conversion (inadequate compartmentation & smoke control facilities) then usually the whole building requires cover, even the independent one.

This isn't an uncommon situation and focuses on property and land legislation - where an escape route goes onto another person/entities land there usually needs to be a legal agreement, license, easement, deed of variation or similar to allow right of access for escape without trespass. Where no agreement exists a landowner is entitled to deny access. You will need to contact a specialist on land/property law for advice.

Yes, like any other communal service like common area lighting, cleaning, external landscaping (if gardened), block insurance, etc it would be a typical Service Charge item.

Look here; https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/937931/ADB_Vol1_Dwellings_2019_edition_inc_2020_amendments.pdf

900mm if there is any chance a wheelchair may need to pass, more if large numbers need to pass

They can insist, but they can't instigate legal proceedings unless it falls under s257 of the Housing Act, namely: - a building that is declared an HMO by the local authority. a converted block of flats where the standard of the conversion does not meet the relevant building standards* and fewer than two-thirds of the flats are owner-occupied *if the conversion was completed before 1 June 1992, it should comply with Building Regulations in force as of 1 June 1992 Only where the particular authority has included these properties in an additional licensing scheme do they require a license. They can only make you do this by issuing an Housing Health and Safety Rating System (HHSRS) Improvement Notice under the Housing Act The recipient may make an appeal to the First-tier Tribunal (Property Chamber) against an improvement notice or a prohibition order. An appeal against an improvement notice could include an appeal on the merits of the works required by the notice. If the Fire Safety Order is to be used then only the Fire & Rescue Service can take Enforcement Action and on receiving an Enforcement or Prohibition Notice you can appeal it via the Magistrate's Court or where you agree that there is a need for improvements to fire precautions but disagree on the technical solution to be used, they may agree to refer the issue to the Secretary of State for Communities and Local Government for independent determination under article 36 of the Order.

Cupboards under 1sq.m. can be omitted without a variation, however it's not uncommon to see them fitted anywhere. I know of several homes that have had enforcement action to make them fit them too. There is a risk of spontaneous combustion in linen after being laundered, dried , folded, and stacked particularly where contaminated with oils and similar not removed by washing with paraffin based emollients being a particular issue in recent times - fire risk isn't just the obvious and architects historically aren't the most knowledgeable in relation to fire safety. Ultimately the Fire Risk Assessment will decide if the risk is low enough to omit detection as well as identify the long list of fire safety snagging all too common in premises after refurb (& the meaningless 'sign off')

Usually they are built with them, most kiosks are small enough for the travel distances to be short enough not to need a designated exit. There is the forecourt risk, but you can isolate the pumps from the counter and shouldn't have an incident growing so fast as to cause a problem.

Yes, it's rare outside of high risk environments to need to evacuate whole sites. It's horribly expensive and disruptive in lost time and leads to more people than necessary needing control, moving out of the way of the fire service and possibly shelter and sustenance if the weather is extreme and the incident protracted.

Depending on the size and layout of your shop, the fire detection provision and the contents of the cupboard (e.g. just storage or storage and an ignition risk such as an electrical board) your Fire Risk Assessment (which will now require review as you are carrying out a significant change) may determine a normal door is acceptable, or an FD30 or FD30S fire doorset. Usually if determined to be a place of special fire risk you are looking at FD30 (30 minute fire doorset with intumescent seals) or if needed to preserve a protected escape route the door is on a FD30s door (30 minute fire doorset with intumescent seals & cold smoke brush). If you do need a fire door it would need an EN1154 approved self closer unless infrequently accessed where, as a cupboard, it can be kept locked shut instead. I can't commit for sure as I haven't seen the premises.

The hall detector would be attached to a heat detector and sounder in the flat with separate smoke and heat detectors for the flat itself

It's still not a requirement for the door to have a certification mark, it makes identifying the door more difficult but isn't the end of the world. It's far easier to rebead the glazing with the correct intumescent than replace the door and frame (if they don't replace the frame then any new door certificate would be invalid as certification is for door sets (frame, ironmongery, etc) not just the door.

The face of the building (excluding window openings) should provide at least 30mins fire resistance and window openings should not extend below a height of 1100 mm above the deck level. Surface materials of the facing wall, balcony soffit and balustrade should be of Class 0 rating. The idea is that if fire escapes the flat through the window, occupants needing to pass by the flat can crawl beneath and hopefully escape. If entrance to each flat is afforded via external balcony / deck approach you need to check the width (less than 2m in width is fine). There is a risk of smoke logging if the balcony / deck above is more than 2m. The requirement is for the doors to be FD30 level If its the furthest flat from the stair this may be relaxed.

Yes, discount the largest and it's numbers - e.g. if you had a 100 person capacity exit and a 200 capacity one you would assume 300, but have to discount the larger bringing you down to 100. The 60 is where you only ever had one exit in the first place.

Yes - any building in England & Wales containing 2 or more dwellings comes under the Fire Safety Order 2005 as amended by the Fire Safety Act 2021 and requires a Fire Risk Assessment of all common parts, the exterior of the building (walls, windows, doors, balconies) and all flat front doors). The legislation only requires that the person carrying it out is competent to provide a suitable & sufficient FRA, however in a lot of cases agents aren't competent and use an external specialist, preferably one with third party accreditation or on a fire risk assessors register. Whilst there are some fire safety obligations under the Fire Safety Order that would come up in an FRA which you will have to implement that will not have been previously dealt with by Building Regulations, if your conversion has gone through the correct Building Control process there should be no major issues arising.

They do look like the original fire doors that are to the standard of the time with the upgrades as already mentioned. They would be acceptable under both the existing flats guidance and based on the draft for consultation would still be acceptable under the new small blocks of flats guidance produced to account for the Fire Safety Act's amendment of the fire safety order. Unless you see something in writing from the Council that you have verified is really from them I'd do nothing and even if something does then I'd ask a competent person to look at their rationale & put forward a rebuttal if needed. Could be a confidence trick, wouldn't be the first fire safety related one I've heard of.

Why not? If it's the highest set of doors on the stair they don't need to be fire doors.

The existing (outgoing) fire safety in purpose built flats guide states this. It's draft replacement for small blocks (G-2) takes a similar approach, I'm not sure what it's replacement for large blocs will says although it's normally required for large blocks regardless of borrowed light, but secondary to issues such as fire doors (so they could be done later on in another budget period)

I think there are several legal and ethical issues here, especially if it isn't a secure unit with Deprivation of Liberty authority and plans. Locking the rooms as part of emergency lockdown is one thing, all the time is another!

You would need a fire safety specialist to assist the design team as this would be a complex development spanning various different guidance (ADB, BS9999, BB100, etc) and thus requiring a bespoke design fire strategy.

Unless large numbers are involved you are probably right that it's OK - the fire exit argument may be a screen for a wider parking dispute.

In small buildings only one exit stair is perfectly legal - rope ladders are not! The stair would need to be a protected route. To answer your questions in full would warrant carrying out a Fire Risk Assessment of the site - which should have been carried out as a legal requirement for both the commercial and residential parts, the commercial one having to consider the effects of a fire on the flats above.